David Rosenthal has formulated recommendations for an adaptation of the draft – based, among other things, on the message on the DPA. The recommendations are available here with the kind permission of the author: Link (PDF)
The Association for Corporate Data Protection (VUD) as a professional organization of operational data protection specialists, supports these recommendations.
The recommendations and detailed explanations are expected to be published in a corresponding essay by David Rosenthal entitled “The draft for a new data protection law: what awaits us and what still needs to be corrected” in the Jusletter of November 27, 2017.
Update 27 November 2017: The contribution is on 27.11.2017 in Jusletter published.